Add a good-guy screening exclusion

Some customers share a name with someone on a sanctions or PEP list and are matched every time they are screened. A good-guy exclusion records that this customer is not that listed party. While an approved exclusion is in force, screening skips that pair, so analysts stop clearing the same false positive over and over.

Before you start

• To propose an exclusion you need list-management rights: MLRO, Deputy MLRO, Administrator or List manager.
• To approve an exclusion you need the MLRO, Deputy MLRO or Screening checker role, and a second factor for step-up. You cannot approve an exclusion you proposed.
• Analysts and Senior analysts can see the Exclusions page and benefit from exclusions, but cannot propose them.

Note: An exclusion covers one customer and one list entry. It does not stop the customer being screened against any other entry or list.

Propose an exclusion

Exclusions are proposed from a screening hit, so you start from the evidence.

1. Open the hit from the Hits queue at /screening.
2. Compare the subject and the list entry in the Side by side view and the Reading column. Make sure attributes such as date of birth, nationality or identifier clearly differ.
3. Select Propose exclusion.
4. Give a reason that explains why the customer is not the listed party.
5. Set an expiry date. An exclusion can last at most three years.
6. Submit the proposal. It now waits for a checker.

Tip: Propose an exclusion only after the hit has recurred and been cleared at least once on firm evidence. A single hit is better handled with a normal clear, which FlowSentry also remembers.

Approve or reject an exclusion

1. Open Exclusions in the Screening module, or go to /screening/exclusions. The page is titled Good-guy exclusions.
2. Choose the Awaiting a checker view.
3. Open the proposal and review the reason and the underlying hit.
4. Choose one:
   • Approve. You will be asked to confirm with a fresh second factor if you have not done so in the last five minutes.
   • Reject, with a reason.

What happens next

Once approved, the exclusion is in force. Screening skips the pair in:

• real-time screening of new activity
• onboarding screening
• rescreens of the whole book, for example after a list update.

The proposal, the approval and the names of both people are recorded in the audit trail.

Keep exclusions current

• The In force view shows every active exclusion.
• Expiring in 30 days shows exclusions that will lapse soon. Review them: if the reason still holds, propose a new exclusion before the old one expires; otherwise let it lapse and hits will be raised again.
• If you learn something that undermines an exclusion, raise it with your MLRO straight away.

Warning: An exclusion silences screening for that pair. Do not use exclusions to work through a backlog, and take particular care with entries on statutory sanctions lists, where a missed true match has the most serious consequences.

Related

• Clear several screening hits at once
• Review a screening hit
• Screening and risk FAQ